Verband kommunaler Unternehmen e.V.

Positionspapier zum Omnibus-Paket der EU-Kommission zur Vereinfachung der digitalen Gesetzgebung und der KI-Verordnung Brüssel, 10. Februar 2026 Unsere Ziele: • Weniger Bürokratie Ressourcen. Wichtig ist, dass auf die Vorschläge der Kommission nun schnelle Verhandlungsabschlüsse folgen. Nur so haben kommunale Unternehmen Planungs- und Rechtssicherheit.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The German Association of Local Public Utilities Verband kommunaler Unternehmen (VKU) represents over 1,600 local public utilities in Germany, operating in the sectors of energy, water/waste water, waste management and telecommunication. We enclose our position paper on the European Commission's consultation on the Digital Omnibus.

The VKU is grateful for the possibility to present the proposal to amend the Directive. to comment on the promotion of the use of energy from renewable sources. VKU positions in the near future (see detailed opinion attached): — The use of renewable and otherwise sustainable and greenhouse gas neutral electricity produced for the production of heat and gas, Fuels and industrial manufacturing processes (“sector…

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The Association of Municipal Enterprises (VKU) represents over 1590 municipal and municipal companies in the fields of energy, water/waste water, waste management and telecommunications. More and more member companies are engaged in broadband roll-out: Around 220 companies invest over EUR 912 million per year. We enclose our position paper on the European Commission’s call for evidence on the Digital Networks Act.

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The Association of Municipal Enterprises (VKU) welcomes the European Commission’s extensive efforts to contribute to waste prevention and better recycling through the new Packaging Ordinance (PPWR). This requires in particular sound eco-design, the use of recycled materials, rules on placing on the market and clarification of reuse and disposal, which the European Commission rightly recognises.

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From the point of view of local government, the proposed simplification of ESRS is to be welcomed. It is also important to continuously revise the data points. The significant reduction in the number of data points to be disclosed represents a good balance between simplification and obtaining the necessary information to meet the objectives of the Green Deal.

Filed in German · English published by the European Commission

The VKU is grateful for the opportunity to comment on the Commission’s proposal for a regulation on harmonised rules for artificial intelligence. We welcome the risk-based approach taken by the Commission in its proposal. This does not affect the majority of AI applications as they do not pose any risk. It is important now that the scope of the proposal for a regulation covers only suitably risky schemes.

Filed in German · English published by the European Commission

The Association of Municipal Enterprises (VKU) e.V. welcomes the European Commission’s initiative to review the 2018 Waste Framework Directive. This is an important and appropriate step to reduce waste generation and improve separate collection.

Filed in German · English published by the European Commission

From the viewpoint of the VKU, the proposal for a certification framework for carbon removals is an important step towards achieving the objective of climate neutrality by 2050. Uniform standards are appropriate to objectively ensure the accounting of greenhouse gases in the EU. However, its success from the perspective of the VKU requires an ambitious balancing act.

Filed in German · English published by the European Commission

Waste-to-energy (Wte) is a key component of modern circular economy systems. It ensures the safe, hygienic and environmentally sound management of non-recyclable waste, while at the same time contributing to the supply of energy in the use of waste heat, in particular through the provision of electricity and district heating.

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With the Green Deal, the European Commission has for the first time taken a holistic approach to tackling climate and environmental challenges in Europe. The VKU warmly welcomes the Commission’s position on the circular economy and the associated sustainable product policy initiative as a key element of the Green Deal.

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The VKU is grateful for the opportunity to comment on the draft revision of the Energy Efficiency Directive. With the revision of the EED, the future framework of EU energy efficiency policy will: tension until 2030 and partly beyond. What can be inferred from this national implementation options are high for VKU member companies economic relevance.

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The VKU is grateful for the opportunity to comment on the European Commission’s proposal to amend the European Emissions Trading Directive 2003/87/EC, Decision (EU) 2015/1814 on the establishment and operation of a market stability reserve for the greenhouse gas emission allowance trading scheme and Regulation (EU) 2015/757.

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Positionspapier r zur Überarbeitung des EU-Rechtsakts zur Cybersicherheit Sondierung der EU-Kommission Kernforderungen der Kommunalwirtschaft: • Bürokratie abbauen; • Security-by-Design als Grundelement sicherstellen; • Gänzliche Sicherheit in der IKT-Lieferkette verankern.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The VKU is grateful for the opportunity to comment on the Commission’s impact assessment on the so-called Data Act. Position of the VKU in the near future: The VKU welcomes the Commission’s intention to use private sector data for the common good.

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The Verband Gemeinder Unternehmen e.V. (VKU) represents over 1,550 municipal works and municipal companies in the fields of energy, water/waste water, waste management and telecommunications. With more than 300.000 employees, revenues of EUR 141 billion were generated in 2021 and more than EUR 17 billion were invested.

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The Association of Municipal Enterprises (VKU) welcomes the European Commission’s proposal to adapt the 2006 Batteries Directive to current circumstances and trends. This initiative to set sustainability requirements along the value chain will be a key element to pave the way for circular, sustainable and safe batteries of all kinds, in line with the Green Deal and the new Circular Economy Action Plan.

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The VKU welcomes the European Commission’s work on sustainable finance. However, in order to ensure the effectiveness of reporting obligations to achieve the sustainability and climate objectives, the VKU considers that adjustments to the Commission’s draft are still needed. In the following, the VKU assesses the key provisions of the proposal for a directive from the point of view of local government.

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Berlin, December 09th 2022 Verband kommunaler Unternehmen e.V. [address removed] BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. [address removed] www.vku.de www.bdew.de Remarks Cyber Resilience Act Position Paper of the German Energy and Water Industries and Local Public Utilities EU Transparency-Register-ID BDEW: EU Transparency-Register-ID VKU: 20457441380-38 1420587986-32 The German Association of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association of Municipal Enterprises (VKU) represents 1601 municipal companies and municipal companies in the fields of energy, water/waste water, waste management and telecommunications. Our views on the proposed initiative can be found in the attached opinion.

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VKU would like to highlight seven key points for consideration regarding the transformation of the gas distribution networks and the role of gas distribution system operators in building a competitive European H2 economy. The propositions are being addressed in greater detail in the paper attached – please have a look.

The process of amending the European Directive on the deployment of alternative fuels infrastructure (2014/94/EU, AFI Directive, AFID) is necessary to follow technical progress in the development of charging infrastructure and vehicle technologies.

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FEEDBACK On the Commission’s “Call for evidence”: “CO₂ market and infrastructure in the EU“ Brussels/Berlin, September 11th 2025 Transparency register number: 1420587986-32 The German Association of Local Public Utilities „Verband kommunaler Unternehmen” (VKU) represents more than 1,600 local public utilities in Germany, operating in the sectors of energy, water/waste water, waste management and telecommunication.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association of Municipal Enterprises (VKU) e.V. welcomes the European Commission’s proposal to amend the 2006 Waste Shipment Regulation: It is right and necessary to further restrict exports of plastic waste in particular. On the one hand, exports, especially to distant third countries, are harmful to the climate, as emissions occur during transport.

Filed in German · English published by the European Commission

The European Commission's proposal for the revision of the Urban Wastewater Treatment Directive (UWWTD) provides for a comprehensive revision of the Directive as well as a far-reaching extension of its scope and is of central relevance for the local public wastewater sector in Germany.

The European Commission has for the first time adopted a holistic approach to tackling climate and environmental challenges with the Green Deal. The VKU welcomes the roadmap’s objective of closely linking the revision of the EU Urban Waste Water Directive (UWWTD) to the Green Deal and the “zero pollutant” objective set out therein. In principle, the UWWTD has proved its worth.

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The Association of Municipal Enterprises (VKU) strongly supports efforts at EU level to cut red tape in order not only to help the economy and society cope with current crises, but also to facilitate the efficient implementation of the upcoming transformation processes. The announcement of the review of the SME definition in the Communication from the European Commission on the SME Relief Package is central to this.

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Dear Sir/Madam, the Federal Association of Municipal Leadership Associations (BV) and the Verband kommunaler Unternehmen e.V. (VKU) welcome the fact that the NIS 2 Directive is intended to raise cybersecurity standards throughout the European Union.

Filed in German · English published by the European Commission

The Verband kommunaler Unternehmen e.V. (VKU) represents over 1600 companies in the distribution and disposal sector in Germany. Water supply and sanitation are key components of municipal services of general interest. The VKU welcomes the initiative to develop a research and innovation strategy for water resilience. Europe faces major water challenges.

Filed in German · English published by the European Commission

The VKU welcomes the Commission’s efforts to promote the European Data economy. By developing digital innovations, public Companies already make a significant contribution to modern services of general interest in Germany, this ensures quality of life, stability and local attraction.

Filed in German · English published by the European Commission

The Verband kommunaler Unternehmen e.V. (VKU) represents over 1600 companies in the distribution and disposal sector in Germany. Water supply and sanitation are at the heart of municipal services of general interest. The VKU welcomes the Commission’s intention to accelerate the digitalisation of the water sector and the Commission’s assessment of this issue.

Filed in German · English published by the European Commission

The Association of Municipal Enterprises (VKU) welcomes the European Commission’s objective of setting harmonised EU-wide end-of-waste (EoW) criteria for thermoplastics for the first time with this draft implementing regulation. A single regulatory framework offers opportunities for reliable source streams, higher recyclate quality and compliance safety.

Filed in German · English published by the European Commission

The Association of Municipal Enterprises (VKU) welcomes the Commission’s approach to introduce a rating system for data centres (DCs) in Europe. Sustainability plays an important role in the development of refrigeration centres in Europe. At the same time, regulation should follow the Commission’s current agenda of cutting red tape. Otherwise, there is a risk that the extension will be slowed down.

Filed in German · English published by the European Commission

The German Association of Local Public Utilities (VKU) represents 1.601 local public utilities in the fields of energy, water/wastewater, waste management and telecommunications. Our position on the European Commissions consultation on the implementing regulation on "public procurement of clean technologies minimum requirements on environmental sustainability" can be found in the attached document.